AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Defendant was charged with fraud after allegedly misappropriating funds owed to a client. A scheduling order was issued by the district court, setting deadlines for witness lists and contact information. The Defendant filed her witness list late, including nine witnesses not previously disclosed to the State, leading to their exclusion by the district court as a sanction for violating the scheduling order. The Defendant entered a conditional guilty plea, reserving the right to appeal the exclusion of her witnesses (paras 2-3).

Procedural History

• Appeal from the District Court of Bernalillo County, Charles W. Brown, District Judge, March 25, 2019.

Parties' Submissions

• Defendant-Appellant: Argued that the district court abused its discretion by excluding her witnesses without considering her culpability, the prejudice to the State, and the availability of lesser sanctions. Also argued that she received ineffective assistance of counsel (para 1).
• Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

• Whether the district court abused its discretion by excluding the Defendant's witnesses as a sanction for violating a scheduling order.
• Whether the Defendant received ineffective assistance of counsel.

Disposition

• The Court of Appeals reversed the district court's order sanctioning the Defendant by excluding her witnesses and remanded for further proceedings consistent with LR2-400.1, Harper, and Le Mier. The Court did not consider the Defendant’s claim of ineffective assistance of counsel (para 16).

Reasons

• The Court of Appeals, with an opinion authored by Judge Jacqueline R. Medina and concurred by Judges J. Miles Hanisee and Megan P. Duffy, found that the district court abused its discretion in excluding the Defendant's witnesses without adequately considering the Defendant's culpability, the prejudice to the State, and the availability of lesser sanctions. The Court emphasized the necessity for district courts to make an adequate record explaining their decisions regarding sanctions, as required by the guidelines established in State v. Harper and clarified by State v. Le Mier. The Court noted that the district court failed to assess the Defendant's degree of culpability, the prejudice to the State, and whether lesser sanctions were considered before excluding the Defendant's witnesses. The Court reversed and remanded the case for further proceedings, instructing the district court to consider the Harper and Le Mier factors in determining appropriate sanctions for the discovery violation (paras 4-15).